Saturday, August 09, 2008

A horribly broken FCC SLD

I've attempted to help a poor inner-city Catholic school for several years. This is the grade school where my deceased father-in-law went. My contributions related to IT services. Many times my company billed for those services. Many times we didn't. But my personal contribution was applying for subsidies offered by the FCC's Universal Service Fund for Schools and Libraries.

Never has there been a labyrinthine government program that abused its intended beneficiaries the way this program abuses poor schools. I have pounds of paperwork in files I'd rather shred - but hold onto out of a sick desire to recall just how bad this program is.

In fairness, I'm sure my disregard for this program is naive. Most government programs are probably worse. FEMA comes to mind in the Hurricane Katrina debacle. But most abused must be welfare clients. Fortunately, I have dodged becoming a client of those services so far.

After years of dealing with a certification, application, payment and validation system inspired by the Marquee de Sade, I finally decided I had had enough and opted out. My brief note of regret to be leaving the program generated an automated reply that I couldn't be released until I asked in the right way!

So I called up the always polite support persons that handle this sort of thing, was directed to the right form, completed it (or so I thought) properly, and faxed it over. I was greeted this week with a resignation rejection letter!! They weren't going to allow me to leave their program until I submitted additional language that they required me to include, verbatim, in my request to leave:

We have received your request to revise your Service Provider Identification Number (SPIN). We are unable to process your application for the following reason(s):

Certification Letter is incorrect (Certification Statement is missing). This paragraph must appear exactly word for word on the certification letter. Please see Form 498 Instructions, Page 20, Attachment B, for the exact format and precise wording required for this document.

In another follow-up call I challenged the always polite staff at the FCC to the following simple tasks:

1. Give your stupid paperwork to your mother. See if she can figure it out. Most principals at small schools are dedicated women who have way to much to do. They are of above average intelligence, but this program is inscrutable! to even the most accomplished of government paperwork pushing savants. If your mother can't do it neither can they.

2. Do a quick survey: find 10 local schools that have an obvious need for the subsidies promised by this program. Look up in your database if they are participating. I predict that most won't be. Of those that are, examine what they are paying for voice and data services. I predict it will be 30% to 50% higher than normal. Why? Because the vendors who have to wade through your program's maze of requirements, filings, certifications and rules are doing what they can to compensate themselves for the agony they must endure to provide services under this system.

My suggestion to the FCC: Write checks to the poorest of poor schools without any application process or hoop-jumping by their beleaguered administration. Give them $50 for each phone line and $200 for Internet service. OK, make them send you a copy of one of their phone bills. (Don't even bother with the bill for the Internet.)

I don't think too many Catholic schools are going to rip you off for the $400/mo you send them to rescue poor kids from the despairing circumstances most of them live in.